East Ayrshire Local Development Plan Summary of Responses Received to Main Issues Report March 2015 PART 1: Summary of comments received at Main Issues Report Stage In the tables below, a summary of responses received to each of the main issues is provided in the left hand side column and the Council’s response to these is provided in the right hand side column. Main Issue 1: Achieving Good Design Synopsis of Main Issue: This issue explores how the LDP can best ensure that high quality design becomes an integral part of the planning process in East Ayrshire Summary of comments Council response Respondents generally agree with the preferred option of ensuring design is Within the MIR, the preferred option was to make design a fundamental an important part of the LDP. element of the planning process by including a core design policy with associated supplementary guidance providing additional detail. The LDP has Caution is requested, primarily from the development sector, in relation to carried this forward by creating an Overarching Policy which applies to all ensuring that any design policy takes account of development viability and is new development and which places significant emphasis on good design. not unduly onerous so as to stifle development. Leading on from this is the place making section which sets out how our places can become more successful in line with the Scottish Government’s 6 qualities of successful places. Design Guidance setting out more detail on design will be prepared as set out in the LDP Action Programme. The proposed plan has taken the same general approach as was stated in the MIR with which respondents were generally in agreement. The Development industry can remain assured that development viability will be a consideration in the assessment of planning applications. However, the Council is of the view that quality design can be achieved without significantly eating into profit levels and that well designed places are generally more economically successful. Additional specific comments: Planning Authorities are required by Section 3F of the Town and Country Building control is the most appropriate means of securing energy Planning (Scotland) Act (as amended) to contain planning polices relating to efficiency. Any planning policy should give flexibility to achieving energy low and zero carbon generating technologies. Policy ENV 14 of the proposed 2 efficiency in different ways, not necessarily with ‘bolt on’ technologies. plan sets this out. Overarching Policy OP1 states that all new development should assist in the delivery of the green infrastructure. Any core design policy should promote the delivery of the green network, promoting linkages with surrounding habitats. Good design should apply to green spaces as well as the built environment, ensuring that green The development industry will be fully consulted on Supplementary Guidance spaces are high value habitats for wildlife. on Design Guidance when it is published. Early engagement with the development industry is vital in developing design guidance. The proposed SPG should be issued alongside the LDP, giving the opportunity for meaningful engagement. The Charrette or Enquiry by Design process is a valuable tool in achieving good quality design for changing places and the Council would advocate its Processes such as ‘Enquiry by Design’ should be used use wherever possible. However, it is recognised that the time and costs involved are significant so in many cases this approach will not be a viable The preparation of computer aided visual representations of new option. developments would help promote high quality design. The Council is of the view that housing in the countryside should require to meet with both rural housing and design policies. There may be a case for encouraging individual houses of outstanding design quality on land not designated for housing. Policy OP1 and the place making section of the proposed plan all promote good connectivity. A design policy should promote enhanced access opportunities, linking to All relevant Council departments were and will be consulted on the design wider access networks than just active travel routes. aspects of the Proposed Plan and associated guidance. The LDP should contain a commitment for all Council depts. to work together in pursuit of high quality design. This is especially relevant to the Roads Authority. 3 Main Issue 2: Recognising and supporting green networks Synopsis of Main Issue: This issue explores how the LDP should support the development of green networks in Ayrshire, specifically linked to the Central Scotland Green Network. Summary of comments Council response The respondents largely support the preferred option of giving policy support The Proposed Plan places significant emphasis on the delivery of green to green networks within the LDP and supporting this with specific SPG. network objectives. Support for its promotion is contained within the Overarching Policy OP1 and in a dedicated Green Infrastructure policy within the Delivering Infrastructure section. The place making section of the plan shows in detail where our existing green networks are situated within Kilmarnock, Cumnock, Stewarton, Galston and Dalmellington and highlights opportunities for making improvements to them. A similar approach will be taken for all other communities as per the LDP Action Programme. Whilst specific supplementary guidance on green networks is no longer proposed, both the place making section and the forthcoming Design Guidance will both promote green infrastructure/network objectives and will result in this issue being a key consideration in future development. The way forward proposed in the Proposed Plan is considered to be broadly consistent with that proposed in the MIR. Given that respondents largely agreed with policy support for green networks, it is considered that the proposed plan approach will also be supported. The Council recognises the links between the green networks and the water environment and it has ensured that the water framework directive and river basin management plans have been taken into account. Within the place making section of the plan where green networks have been mapped, in most cases there is a complementary ‘blue network’ running alongside it. Suggested projects within this part of the plan aim to enhance the blue and Additional specific comments: green network and make it more accessible to, and safer for, the public. 4 Linkages between green networks and the water environment must be recognised. Any SG must relate to the water framework directive and Implementation of the green network policy will take full account of ecological river basis management planning. matters. The East Ayrshire Leisure Trust’s Countryside Manager will actively assist with this process. The green network policy should recognise the recreational value of green networks. The Green Infrastructure policy does recognise their recreational value. The green network policy should promote a network of off-road cycling and walking paths. The priority should be to link public transport facilities The place making section of the proposed plan has examined opportunities to community facilities and housing areas. for the promotion of off road cycling and walking paths. Where these have been proposed, the potential for wider linkages where appropriate has been In developing guidance for large scale redevelopment and greenfield taken on board. sites, it should be ensured that development viability is fully considered. Any site specific requirements should be clearly justified and any Development viability has been considered throughout the proposed plan and supporting information made publicly available. it ensures that any green network initiatives required as part of a development is not too onerous. All requirements will be made public through either the proposed plan or supplementary guidance. Main Issue 3: Reducing the risk of flooding Synopsis of Main Issue: This issue addresses how the LDP can best play its in part reducing the risk of flooding within East Ayrshire. Summary of comments Council response Respondents are generally supportive of the preferred approach that looks The preferred option in the MIR was to reduce the risk of flooding by both at reducing flood risk strategically in terms of taking account of flood risk undertaking a number of measures including, where possible, avoiding the in the allocation of land, and more locally through ensuring flood prevention identification of LDP sites in areas of medium to high flood risk and ensuring measures are put in place in the design of new developments. that Sustainable Urban Drainage Schemes are provided as an integral element of new developments as well as stating that the Council would fulfil its obligations to prepare a Flood Risk Management Plan within agreed legislative timeframes. There was general agreement with this approach. The LDP flooding policy 5 and supporting text takes a similar approach albeit that it has been updated to take full account of SPP 2014. Additional specific comments: Reference should be made to avoidance being the first principle of Reference to avoidance being the first principle is made in the LDP flooding sustainable flood management. Regard should also be had to one of the policy. main duties under the Flood Act, which is an overall reduction in flood risk. There will now be no SPG specifically on green networks. However, clear The links between flood risk and green networks